ENVIRONMENTAL

MONITORING

PLAN

for Imidacloprid 

 

ASIAN LONGHORNED BEETLE ERADICATION PROGRAM

Worcester, Massachusetts 

2010 

 

United States 

Department of

Agriculture 

Animal and 

Plant Health 

Inspection 

Service 

Plant Protection 

and Quarantine 

Prepared by the 

Environmental 

Compliance Team 

 November 2009 version 
2010 Environmental Monitoring Plan 1 

General 

The United States Department of Agriculture (USDA) - Animal and Plant Health Inspection 

Service (APHIS) Directive 5640.1 (4/19/02) commits the Agency to a policy of fulfilling the 

mandates of the National Environmental Policy Act; the Endangered Species Act; the Federal 

Insecticide, Fungicide, and Rodenticide Act; and other statutes that require monitoring the effects 

of Federal programs on the environment. The monitoring described in this Environmental 

Monitoring Plan (EMP) supports these commitments for the Massachusetts Asian Longhorned 

Beetle (ALB) Cooperative Eradication Program. 

Environmental sampling for residues of imidacloprid is proposed to validate the assumptions of 

the Environmental Assessments created for the program and to address specific concerns raised 

by the public. Imidacloprid is a systemic insecticide used as a treatment of ALB host trees at 

risk for infestation. ALB host trees are treated via ground or trunk injection based on the size of 

the tree. Targets identified for monitoring include groundwater, surface water, and non-target 

organisms. Monitoring will be conducted to determine if ALB Program systemic treatments of 

host trees result in the movement of imidacloprid beyond the immediate treatment area. 

Samples collected as part of this plan will be reported to the ALB Program management in an 

annual report. If any residue samples seem unusually high, ALB Program management will be 

contacted immediately to determine what, if any, action may be needed to adjust Program 

operating procedures. This monitoring plan is a working document and will be updated as 

needed based on new information provided to the Environmental Compliance Team. It is 

designed to be a reference document for staff that will work with the Environmental Compliance 

Team to collect and document monitoring samples during the ALB eradication program. 

Training will be provided in early 2010 to field staff on implementing this monitoring plan. The 

monitoring described below is for 2010. The EMP will be updated annually. 

Human and Environmental Health 

Objectives 

Monitoring for potential exposure is designed to: 

1. demonstrate the effectiveness of ALB operational procedures in excluding or minimizing 

exposure of the public of the environment to Program-applied imidacloprid; 

2. collect data which can be used to evaluate whether the assumptions used in the Environmental 

Assessments are valid estimates of potential exposure of the public and the environment 

to Program-applied imidacloprid; and 

3. investigate any Program-related complaints or reports of adverse effects on public health, 

worker safety, environmental quality, or non-target species. 

Methods 

Sensitive Site Inventory 

The Worcester ALB program will identify sensitive site prior to the initiation of chemical 

treatments. Sensitive sites are areas where the public may be exposed directly chemicals and 
2010 Environmental Monitoring Plan 2 

areas where there are specific concerns about potential impacts due to program activities. At this 

time, the only direct exposure potential for people could be via the consumption of water (dermal 

contact is not considered a significant route of exposure). The program will identify any ground 

or surface waters used as a source of drinking water in or adjacent to the proposed treatment 

area. Additional sensitive sites may include, but are not limited to, the location of apiaries. 

The locations will be provided to the ECT. It is preferred that these lists be submitted in an 

electronic form, but they may also be submitted as a printed hard copy. Note the name and 

location of the water, the type of water (ground, surface, lake, etc.), and the distance and 

direction from the nearest treatment area. Prior to the start of chemical treatments, provide the 

list of sensitive sites to the ECT at the following address: 

Dr. Robert Baca, USDA-APHIS-PPQ, 4700 River Road, Unit 150, Room 5A-04b, 

Riverdale, MD 20737 or via email to robert.m.baca@aphis.usda.gov

Surface Water samples

Surface water samples will be collected near the shore of ponds, lakes, or reservoirs, with 

priority given to any identified as a source of drinking water. PPQ personnel have identified 

several surface water stations that are representative of Worcester area watersheds (see attached 

map). About one week before the start of treatments in 2010, pre-treatment samples should be 

taken from chosen surface water sites. Additional samples should be collected at these stations 

approximately one week following treatments and then one, three, and six months later. Care 

should be exercised to ensure the water samples are free of turbidity and sediment. 4.8 liters of 

water will be collected for analysis from each sample station. (For minimum sample sizes for all 

sample types, see the last page of this document.) Following collection, samples will be kept on 

ice, in the dark, and remain chilled until they can be frozen for shipment. For more detailed 

information on sampling procedures, refer to SOP EM-03 Collection of Water Samples, available 

at http://www.aphis.usda.gov/plant_health/plant_pest_info/emt/support_docs.shtml. 

Groundwater samples

Groundwater monitoring wells, installed as part of third-party subsurface environmental 

investigations, have been identified in the City of Worcester, and the Towns of Holden, West 

Boylston, and Shrewsbury. The ECT is working to obtain permission to gain access to these 

monitoring wells for residue sampling. Samples will be collected from the unconfined aquifer 

(i.e. water table) at chosen sites prior to the initiation of the spring 2010 programmatic chemical 

treatments, approximately one week following treatments, one month following treatments, and 

at two-month intervals thereafter. 

Each time groundwater samples are collected, the volume of water in each well will be 

determined. If possible three well volumes will be purged and the well will be allowed to 

recharge before taking the sample for analysis. Samples will be obtained using well bailers, 

peristaltic pumps, or submersible pumps depending on the well location and depth to water. 4.8 

liters of water will be collected for analysis from each well. Following collection, samples will 

be kept on ice, in the dark, and remain chilled until they can be frozen for shipment. For more 

detailed information on sampling procedures, refer to SOP EM-14 Collection of Groundwater 

Samples, available at 

http://www.aphis.usda.gov/plant_health/plant_pest_info/emt/support_docs.shtml. 
2010 Environmental Monitoring Plan 3 

Leaf Litter Samples 

Whenever possible leaf litter samples will be collected each time ground- and surface water 

samples are collected. Leaf litter will be collected around the treated trees (no conifer needles) 

near and up-gradient of the monitoring wells. If no leaf litter is available, please note that on the 

2060 Environmental Monitoring Form for the groundwater sample. Do not collect leaves that 

are on trees if no leaf litter is available. For more detailed information on sampling procedures, 

refer to SOP EM-07 Collection of Vegetation Samples, available at 

http://www.aphis.usda.gov/plant_health/plant_pest_info/emt/support_docs.shtml. 

Bee-Related Samples 

The Agricultural Research Service (ARS) of USDA is working cooperatively with APHIS to 

investigate the response of bee hives to imidacloprid treatments in the Worcester area. The ARS 

experiment is very thorough with strong analytical capabilities. Any monitoring conducted as 

part of this plan will be used to supplement the samples collected by ARS, and will not seek to 

duplicate their work. 

If safe and practical, the Program should work with local beekeepers to collect bee and honey 

(from the hive) samples. As sampling through time is expected, it is optimal to work with 

beekeepers who will agree to multiple sampling events each year. Preference should be given to 

beekeepers with hives in proximity to treatments, but sampling is encouraged throughout the 

Worcester area. 

Bee and honey samples should be collected from each hive. Samples should be collected prior to 

the start of spring treatments, approximately one week following treatments, one month 

following treatments, and at two-month intervals thereafter. A single sample of bees from a hive 

should comprise 25 or more bees. Healthy bees should be collected whenever practical, placed 

in a foil bag, and frozen prior to shipping (for details, see SOP EM-08 Collection of Insect 

Samples). A single honey sample from a hive should be 50 ml, and need only be kept dark prior 

to shipping. Freezing the honey may break the glass sample container. 

Monitoring for Incidents or Complaints 

Priority sampling will be conducted to investigate incidents of unknown origin involving nontarget species or other unintended environmental or human health impacts possibly associated 

with Program-applied imidacloprid. Information about priority sampling can be found in SOP 

EM-09, Priority (Emergency) Sampling. Collect priority samples as soon as possible after the 

complaint, request, or problem is reported. Contact the ECT at (301) 734-7592 or 734-8247 to 

collaborate on a sampling plan, sampling methods, and types of samples to collect in order to 

optimize the investigation. If the incident occurs on a weekend, commence the investigation and 

sampling without delay, and contact the ECT as soon as possible on Monday. 

Proper documentation of the incident, investigation, and samples is extremely important. When 

responding to priority incidents, send to the ECT all GPS maps showing the site, location where 

samples were collected, the nearest treatment area, and treatment history. Be sure to completely 

fill out all information on the APHIS 2060 forms with each sample. Be sure to provide an 
2010 Environmental Monitoring Plan 4 

incident/complaint report to the ECT, along with any other information that you feel will be 

helpful in resolving the incident (i.e. photos, observations at the site, etc.). 

Endangered and Threatened Species 

There are no federally protected species in the eradication area at this time. Should the 

eradication area expand to areas where protected species become a concern, monitoring may be 

required and this monitoring plan will be updated accordingly. 

Sample Processing 

Documentation 

Complete a separate APHIS 2060 form for each sample collected. (A blank copy is below for 

reference. Please only use original 2060 forms supplies by the Gulfport Laboratory for 

documentation.) Instructions for completing the APHIS 2060 forms are on the back of each 

form. All appropriate sections of the form should be completed. Samples should be marked as 

“routine” unless they were collected for a complaint or incident investigation where they should 

be marked as “priority.” For each sample, submit the blue copy of the APHIS 2060 form to the 

Center for Plant Health Science and Technology (CPHST) in Gulfport, Mississippi with the 

sample; the white copy of the form to CPHST in the sample shipping container but separate from 

the sample; and the yellow copy of the form (and any maps, photos, etc.) to the Environmental 

Compliance Team (ECT) in Riverdale, Maryland. The pink copy is retained by the sample 

collector. 

Shipment of Samples 

Ship all samples using some form of overnight delivery. See SOP EM-17, Packaging and 

Shipping of Samples for details. Do not ship samples using USPS Priority Mail or standard 

ground service with other carriers. Overnight delivery allows the sample to stay frozen. 

Shipping any other way will take no less than two to three days and can ruin the samples. Be 

sure that all samples are frozen (except for honey), shipped in a cooler box (not a regular 

cardboard box), and kept cold during shipment. To keep samples cold, ship samples on ice. Do 

not use dry ice, since it will cause the sample containers to crack or break. Either use “blue ice” 

containers (the reusable plastic containers with the blue liquid/gel inside) or contained regular ice 

(that is, seal the ice in zip-loc bags). Unsealed ice will melt and leak during shipment, causing 

unnecessary concern when received at the laboratory. 

Supplies 

Most supplies for monitoring are ordered through the CPHST Gulfport Laboratory, although 

certain supplies are obtained locally. A checklist for ordering supplies is located below. This 

checklist is used by all APHIS pest control programs, and several of the supplies listed do not 

pertain to the ALB Program. The Gulfport Laboratory prefers that supply orders be faxed to 

them using the numbers listed on the checklist rather than leaving a voice message for orders. 
2010 Environmental Monitoring Plan 5 

Responsibilities 

APHIS-PPQ Environmental Compliance staff in Riverdale, Maryland will:

1. Review and interpret field and pesticide residue data from the sample collectors and the 

laboratory. Contact the sample collector for clarification as soon as possible if any field 

data is incomplete or unclear. Notify the Program Director or Manager immediately if 

any residue data is unexpectedly high in value. 

2. Provide training, clarification, and interpretation on how to implement the Environmental 

Monitoring Plan. 

3. Submit a comprehensive interpretive report to the Program Director and the National 

Coordinator within 60 working days of receiving all of the Program’s field data and 

sampling results. 

APHIS-PPQ Center for Plant Health Science and Technology Laboratory staff in Gulfport, 

Mississippi will: 

1. Prepare and ship supplies required for the collection, stabilization, and shipment of 

environmental monitoring samples. 

2. Provide training on methods for collecting, handling, preserving, and shipping samples. 

3. Respond to requests for additional information by field personnel when special sampling 

requirements occur. 

4. Analyze monitoring samples according to standard operating procedures for imidacloprid. 

5. Complete analyses and report results on the following schedule: 

a. Within 23 working days after receipt, complete analyses of all routine samples and 

send results to the ECT. 

b. Within 5 working days after receipt, complete analyses of all priority/emergency 

samples and send results to the ECT. 

c. Contact ECT if the projected completion schedules need to be extended due to sample 

load or laboratory instrument problems. 

6. Forward copies of all environmental monitoring forms and any attached documentation to the 

ECT each week via overnight mail. 

APHIS-PPQ Field Personnel or Cooperators, will:

1. Ensure that sufficient resources from the Program are allocated for completing the monitoring 

activities described in the Environmental Monitoring Plan (EMP). 

2. Follow instructions in the EMP and referenced SOPs to develop a plan for sample collection 

and documentation, including: 

a. Collection of the type and number of samples recommended in the EMP. 

b. Completion of a separate APHIS 2060 form for each sample that is collected. 

c. Providing all the information necessary to document the samples. Send all supporting 

documentation, including a copy of the appropriate APHIS 2060 forms to the ECT. 

Send all samples and appropriate APHIS 2060 forms to the laboratory. Ship all 

samples and supporting documentation in accordance with protocols and procedures. 

d. Notification of the laboratory prior to shipping any priority, spill, or unusual (i.e. 

other than water, insect, or vegetation) samples. 
Sampling Supply Checklist / Order Form 

ENVIRONMENTAL MONITORING SUPPLIES CHECKLIST

SUPPLIES TO BRING EACH TIME YOU GO TO A SAMPLING SITE

Monitoring plan/SOP’s Obtain from ECT Thermometer 

Field log notebook Ice chest/wet or blue ice Obtain locally 

Compass Baby wipes 

Wind gauge 2060 monitoring forms 

Indelible marker Packing/strapping tape 

A.R.S.E. (Run-off Sampling) Dye Cards

Plexiglas cover Oil sensitive dye cards 

8"x 8" mesh screen Water sensitive dye cards 

Tent pegs/nails 5' bamboo poles/stakes 

Funnels attached to caps Paper/alligator clips 

500 ml bottles Tacks 

4" PVC pipe, 14" long 4" x 4" plastic bags 

Post hole digger 12" x 12" plastic bags 

Pea gravel Tweezers/forceps 

Large rocks/bricks disposable gloves 

Bamboo pole/flagging tape Water Samples

collapsible cubitainer Dissolved oxygen kit 

Sodium sulfate (small vials) collapsible cubitainer 

pH paper/pH meter Sodium sulfate (small vials) 

Sulfuric acid (squeeze bottle) pH paper/pH meter 

Styrofoam ‘coffin’ Acid or base (squeeze bottle) Obtain locally

Vegetation/Fish/Insect Samples Sediment Samples

Pruning sheers/scissors Dredge tied to strong rope

Aluminum foil envelopes 3 gallon galvanized pail

Strapping tape Hand trowel

3" mesh screen

 Aluminum foil envelopes

 
Sampling Supply Checklist / Order Form 

Soil Samples Swab/Wipe Samples

Soil core sampler 3” x 3” sterile cotton pads 

with resealable plastic bag 

3 gallon galvanized pail Metric ruler 

Hand trowel Pencil 

3" mesh screen Disposable gloves 

Aluminum foil envelopes Isopropyl alcohol Obtain locally

Baby wipes 

Neat (Pure) Chemical Formulations Miscellaneous Supplies

Amber glass bottle Labels 

Parafilm Styrofoam coolers/mailers 

Small mailing tubes Freezer Obtain locally

Cat litter/packing material 2 oz bottle for honey samples 

Disposable pipette Resealable plastic bags: 

Pipetting bulb 4" x 4" 

Disposable gloves 6" x 6" 

Protective eyewear 8" x 8" 

 12" x 12" 

Program: _________________________________ Requested by: ______________________________ 

Date: _____________________________________ Phone: ____________________________________ 

Address: ____________________________________________________________________________________ 

____________________________________________________________________________________________ 

____________________________________________________________________________________________ 

To order supplies, indicate the quantity of each items needed. Fax a copy of this form to CPHST Gulfport 

Lab at 228-822-3209 or 228-822-3137. If fax machines are not working, leave a message with the CPHST 

Gulfport Lab supplies manager at 228-822-3106. Please realize that it may be difficult to completely fill order 

for large quantities of materials. 

Note: This is not an exhaustive supply list...items that are not listed here may be available through CPHST 

Gulfport Lab. Not all supplies listed above are required for all pest control programs. 
 

Front page of APHIS Form 2060, the Environmental Monitoring Form.
 

Back page of APHIS Form 2060, the Environmental Monitoring Form 
 

Potential surface water sampling stations. Contact the Environmental Compliance Team at 301-

734-7592 for location details. 

Minimum sample sizes required for imidacloprid analysis for a single sample of: 

(Smaller samples may be possible, but are less reliable. If the minimum sample size is not 

available, collect as much as possible for the sample.) 

Leaves, twigs, bark 50 grams

Soil, sediment 50 grams

Sap, honey 50 ml 

Water 4800 ml 

Bees 25 bees